Offsite Storm Water Alternative Compliance Program
The Regional Municipal Separate Storm Sewer System (MS4) Permit, adopted by the San Diego Regional Water Quality Control Board (RWQCB), provides the City of San Diego (City) discretion to allow new development and redevelopment projects (both public and private projects) to use offsite projects to supplement or entirely replace onsite structural best management practices (BMPs) required to comply with pollutant control and/or hydromodification management requirements. This is referred to as an offsite storm water alternative compliance program (from herein referred to as “program”). The City has elected to create and administer this optional program to enhance flexibility of developing property within the City’s jurisdiction while concurrently incentivizing improvements to water quality in locations that otherwise may not see improvements in the near term.
The program development includes establishing an in-lieu fee structure and a credit system. An in-lieu fee system would allow direct payments by project proponents to provide funding for program sponsor-led water quality and/or hydromodification control projects. A credit system would allow credits generated through projects led by the City or private entities to be exchanged. The credits generated can be traded, sold, or banked for future use. For example, a project proponent that is able to treat a greater amount of area than required as part of project implementation would potentially generate excess credits which could then be purchased by other project applicants in the watershed. To assist in developing the City’s program, the Storm Water Division formed two workgroups:
• The Citywide Workgroup consists of subject matter experts from City departments. The Citywide Workgroup will work closely with Storm Water Division staff to develop the program’s framework, shape the various program elements, and determine the program’s implementation process.
• The Stakeholder Technical Advisory Committee consists of subject matter experts and representatives from the environmental community, development industry, regulatory agencies, and engineering community. This committee will assist the Citywide Workgroup with expertise, to facilitate discussions regarding compliance options and to provide recommendations related to development of compliance programs that may include an in-lieu fee payment system, a credit system structure and/or other offsite compliance opportunities.
The presenters will provide an overview of the program and answer questions pertaining to the development of the program, both from the technical aspect and the stakeholder process aspect. Presentation emphasis will include a discussion of how this program is expected to provide tangible opportunities in storm water quality improvement.